ADA Compliance Documentation Checklist

What this is

Nine documents that together form a defensible ADA compliance record. The quality of the paper trail is what separates a successful good-faith-effort defense from a losing one.

Each document on this checklist serves a specific evidentiary purpose. All nine should exist. All nine should be dated. All nine should be kept together in one folder with version history.

If you can only start three, start three. See the Minimum Viable Folder section at the end.

---

The nine documents

1. Accessibility policy

Purpose. A one-to-two page internal commitment to accessibility, signed by an executive, with a specific conformance target.

Must include.

• Conformance standard (typically WCAG 2.1 Level AA).
• Name and title of the accessibility owner.
• Review cadence, typically quarterly or annually.
• Procurement requirement: new vendors must meet the same standard.
• Training requirement: site-maintenance staff receive annual accessibility training.

Owner. Executive sponsor (CEO or COO) signs it. Accessibility owner maintains it.

Review. Annually, or when the accessibility owner changes.

Signed? ☐ Date of last review: ___________

---

2. Published accessibility statement

Purpose. Public-facing page on your website stating your accessibility commitment, conformance target, known limitations, and feedback channel.

Must include.

• Conformance target.
• Date of last conformance review.
• Known limitations and plan to address them.
• Feedback channel with email and phone.
• Assistive technologies tested against.
• Date the statement was last updated.

Owner. Accessibility owner publishes it. Legal reviews before publication.

Review. Quarterly, or after major site change.

Published? ☐ URL: _______________________________ Last updated: ___________

---

3. Most recent accessibility audit report

Purpose. Formal audit report — internal using a standard framework like WCAG-EM, or external from an accessibility firm.

Must include.

• Scope of the audit (which pages or flows).
• Methodology used.
• Findings list with severity for each.
• Remediation recommendations.
• Date of the audit.
• Name and qualifications of the auditor.

Owner. Accessibility owner commissions and stores it. Auditor signs it.

Review. Annual at minimum. More frequently for high-traffic pages.

Date of most recent audit: ___________ Auditor: _________________________

---

4. Remediation log

Purpose. Running log of every accessibility fix.

Must include per entry.

• Date of the fix.
• WCAG criterion addressed.
• Page or feature affected.
• Description of the change.
• Engineer or contractor who made the change.
• Link to the commit or ticket if technical.

Owner. Engineering or accessibility owner. Maintained as a spreadsheet, Jira label, or dedicated system.

Review. Continuous. The log is an operational artifact.

Started? ☐ Format: ☐ Spreadsheet ☐ Ticketing system ☐ Other: ___________

---

5. Training records

Purpose. Evidence that site-maintenance staff have received accessibility training.

Must include.

• Training material or course name, and vendor.
• Date of each session.
• Attendee list with signatures or acknowledgment timestamps.
• Refresh cadence.

Owner. HR or accessibility owner.

Review. After each session. Audit roster annually against current site-maintenance staff.

Last training date: ___________ Attendees: ___________ Next scheduled: ___________

---

6. Procurement and vendor records

Purpose. Documentation that vendors whose products appear on your site are accessible, or that your compensating controls cover any gaps.

Must include per major vendor.

• VPAT (Accessibility Conformance Report) if they publish one.
• Your evaluation notes if they do not.
• Contract language requiring accessibility where applicable.

Owner. Accessibility owner coordinating with procurement or legal.

Review. At contract renewal for each vendor.

Vendors documented: ___ of ___ major vendors

---

7. User feedback log

Purpose. Records of every accessibility complaint or report received from users, with the response.

Must include per entry.

• Date of the report.
• User's description of the issue.
• Category.
• Your response.
• Resolution date.
• Link to remediation-log entry if applicable.

Owner. Person staffing the accessibility feedback channel.

Review. Continuous. Shows responsiveness, which is a good-faith-effort factor.

Feedback email address: _______________________________ Avg response time: ___________

---

8. Change management record

Purpose. Evidence that accessibility is evaluated before code changes go live.

Must include.

• Pull request template requiring accessibility signoff, OR
• Periodic audit of merged changes showing the accessibility check was performed.

Owner. Engineering lead or accessibility owner.

Review. Quarterly audit of the check's actual use.

Mechanism in place? ☐ Quarterly audit date: ___________

---

9. Incident response plan

Purpose. Document describing what happens when an accessibility complaint or demand letter arrives.

Must include.

• Who is notified.
• Timeline for acknowledgment.
• Internal investigation process.
• Remediation triggers.
• Communication plan for affected users.

Owner. Accessibility owner with legal concurrence.

Review. Annually, or after any incident.

Plan published? ☐ Last reviewed: ___________

---

How to store the folder

• One location. Cloud drive, file server, or document management system.
• Access limited to accessibility owner, legal, and executive sponsor.
• Every document has a version. Each version has a date.
• Old versions retained. Version history is part of the evidence.
• An index document listing what is in the folder, where each lives, who owns it, and last review date. This is what you hand to counsel on day one of a claim.

---

Minimum Viable Folder

If you cannot produce all nine right now, start with three. Consistently maintained, these are more valuable than all nine done once and never updated.

• ☐ Accessibility policy. Half a page. Signed. Dated. Filed in a timestamped system.
• ☐ Accessibility statement. Published on your website. Honest about current state. With a feedback email.
• ☐ Remediation log. Started today. Every fix logged going forward.

Add the other six at a pace you can sustain. The pattern matters more than the completeness.

---

What this buys you

If you are sued and reach discovery, this folder is requested. A complete and current folder sends three signals: you knew about the ADA, you took it seriously, you did the work.

It does not win every case. It does not reverse an accessibility failure. It does not satisfy a plaintiff who wants money.

What it does is shift the settlement conversation. A defendant with a dated audit, remediation log, training records, feedback log, and published accessibility statement settles at the low end of the range — or not at all.

---

What this does not buy you

A folder is not a substitute for an accessible site. A statement claiming WCAG 2.1 AA conformance while the site has hundreds of scanner findings is an admission against interest.

A folder is not a substitute for responsiveness. A user feedback log with complaints that were never addressed is worse than no log.

The checklist works only when the documentation reflects reality. Build the folder alongside the real accessibility work, not instead of it.

---

This checklist provides general guidance, not legal advice. For the application of this framework to your specific business, consult a licensed attorney.

Prepared by Startvest LLC, a service-disabled veteran-owned small business based in Hampstead, NC. Updated [updatedAt]. Additional guidance at adacompliancedocs.com.